Conflict Minerals - Materials From a Non-Verified Smelter


What are the compliance implications for a company that bought products from a verified smelter but the smelter later became unverified yet the company purchased products that will remain in their supply chain for about 10 years or more?


It would be the status of the smelter or refiner at the time of purchase that is paramount. However, during an audit, the company would need a very robust due diligence record linking the purchased materials to the CMRT at the time of purchase. The auditor would want to see that the materials in question were not co-mingled with other materials that could call the declaration trail and status into question.


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